This policy sets out how we will collect, use, disclose and protect your personal information.

This policy does not limit or exclude any of your rights under the Law. If you wish to seek further information on the Law, see www.privacy.org.nz for New Zealand or www.oaic.gov.au for Australia.

Changes to this policy

We may change this policy by uploading a revised policy onto the website. The change will apply from the date that we upload the revised policy.

Who do we collect your personal information fromWe collect personal information about you from:

you, when you provide that personal information to us, including via the website and any related service, through any registration or subscription process, through any contact with us (e.g. telephone call or email), or when you buy or use our services and products ‍third parties where you have authorised this (such as from referees when you apply for a vacant role) or the information is publicly available.

If possible, we will collect personal information from you directly.

How we use your personal information

We will use your personal information to verify your identity to provide services and products to you

to market our services and products to you, including contacting you electronically (e.g. by text or email for this purpose)

to improve the services and products that we provide to you

o bill you and to collect money that you owe us

to assess your application for a vacant role

to assess your suitability for our Talent Pool

to respond to communications from you, including a complaint to conduct research and statistical analysis (on an anonymised basis) ‍to protect and/or enforce our legal rights and interests, including defending any claim for any other purpose authorised by you or the Law.

another company within our group

any business that supports our services and products, including

any person that hosts or maintains any underlying IT system or

data centre that we use to provide the website or other services and products

a credit reference agency for the purpose of credit checking you other third parties (for anonymised statistical information)

a person who can require us to supply your personal information (e.g. a regulatory authority)

any other person authorised by the Law or another law (e.g. a law enforcement agency)

any other person authorised by you.‍a business that supports our services and products may be located outside New Zealand or Australia. This may mean your personal information is held and processed outside New Zealand or Australia.

Protecting your personal information

We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse.

Accessing and correcting your personal information

Subject to certain grounds for refusal set out in the Law, you have the right to access your readily retrievable personal information that we hold and to request a correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.

If you want to exercise either of the above rights, email us at privacy@fronde.com. Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information, or the correction, that you are requesting).

We may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.

Internet use

While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.

If you follow a link on our website to another site, the owner of that site will have its own privacy policy relating to your personal information. We suggest you review that site’s privacy policy before you provide personal information.

We collect technical information about users when they log on to, or visit the public version of, our website. This includes information about the way users arrive at, browse through and interact with our website. We may collect this type of technical information through the use of cookies, and other means. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive to enable our systems to recognise your browser.

If you have provided us with your email address, we track more detailed technical information, including information about the pages of our website that you visit, when, and how long you stay.

We use the technical information we collect to have a better understanding of the way people use our website, to improve the way the website works and to personalise it to be more relevant and useful to your particular needs.

We use a number of third-party analytics and marketing tools to help us collect this information, including Google Analytics, Lucky Orange and Salesforce. For more information on how Google collects, uses, discloses and protects data when you use our website please see How Google uses data when you use our partners’ sites or apps at www.google.com/policies/privacy/partners.

You may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of the website.

Website terms of use‍1 APPLICATION OF TERMS‍1.1 These Terms apply to your use of the Website. By accessing and using the Website:‍a. you agree to these Terms; and ‍b. where your access and use is on behalf of another person (e.g. a company), you confirm that you are authorised to, and do in fact, agree to these Terms on that person’s behalf and that, by agreeing to these Terms on that person’s behalf, that person is bound by these Terms.‍1.2 If you do not agree to these Terms, you are not authorised to access and use the Website, and you must immediately stop doing so. ‍2 CHANGES‍2.1 We may change these Terms at any time by updating them on the Website. Unless stated otherwise, any change takes effect immediately. You are responsible for ensuring you are familiar with the latest Terms. By continuing to access and use the Website, you agree to be bound by the changed Terms. ‍2.2We may change, suspend, discontinue, or restrict access to, the Website without notice or liability.‍2.3 These Terms were last updated on June 2018.‍3 DEFINITIONSIn these Terms:‍including and similar words do not imply any limit‍Loss includes loss of profits, savings, revenue or data, and any other claim, damage, loss, liability and cost, including legal costs on a solicitor and own client basis‍personal information means information about an identifiable, living person‍Terms means these terms and conditions titled Website Terms of Use‍Underlying System means any network, system, software, data or material that underlies or is connected to the Website ‍User ID means a unique name and/or password allocated to you to allow you to access certain parts of the Website ‍We, us or our means Fronde Systems Group Limited and its subsidiary Fronde Australia PtyLimited‍Website means www.fronde.com, www.fronde.co.nz and/or www.fronde.com.au‍You means you or, if clause 1.1b applies, both you and the other person on whose behalf you are acting.‍4 YOUR OBLIGATIONS ‍4.1You must provide true, current and complete information in your dealings with us (including when setting up an account), and must promptly update that information as required so that the information remains true, current and complete.

4.2If you are given a User ID, you must keep your User ID secure and:‍a. not permit any other person to use your User ID, including not disclosing or providing it to any other person; and ‍b. immediately notify us if you become aware of any disclosure or unauthorised use of your User ID, by sending an email to legal@fronde.com.

4.3 You must:‍a. not act in a way, or use or introduce anything(including any virus, worm, Trojan horse, time bomb, keystroke logger, spyware or other similar feature) that in any way compromises, or may compromise, the Website or any Underlying System, or otherwise attempt to damage or interfere with the Website or any Underlying System; and ‍b. unless with our agreement, access the Website via standard web browsers only and not by any other method. Other methods include scraping, deep-linking, harvesting, data mining, use of a robot or spider, automation, or any similar data gathering, extraction or monitoring method.‍4.4 You indemnify us against all Loss we suffer or incur as a direct or indirect result of your failure to comply with these Terms, including any failure of a person who accesses and uses our Website by using your User ID.‍5 INTELLECTUAL PROPERTY ‍We (and our licensors) own all proprietary and intellectual property rights in the Website (including all information, data, text, graphics, artwork, photographs, logos, icons, sound recordings, videos and look and feel), and the Underlying Systems.‍6 DISCLAIMERS‍6.1 To the extent permitted by law, we and our licensors have no liability or responsibility to you or any other person for any Loss in connection with:‍a. the Website being unavailable (in whole or in part) or performing slowly;‍b. any error in, or omission from, any information made available through the Website;‍c. any exposure to viruses or other forms of interference which may damage your computer system or expose you to fraud when you access or use the Website. To avoid doubt, you are responsible for ensuring the process by which you access and use the Website protects you from this; and‍d. any site linked from the Website. Any link on the Website to other sites does not imply any endorsement, approval or recommendation of, or responsibility for, those sites or their contents, operations, products or operators. ‍6.2 We make no representation or warranty that the Website is appropriate or available for use in all countries or that the content satisfies the laws of all countries. You are responsible for ensuring that your access to and use of the Website is not illegal or prohibited, and for your own compliance with applicable local laws. ‍7 LIABILITY ‍7.1 To the maximum extent permitted by law:‍a. you access and use the Website at your own risk; and ‍b. we are not liable or responsible to you or any other person for any Loss under or in connection with these Terms, the Website, or your access and use of (or inability to access or use) the Website. This exclusion applies regardless of whether our liability or responsibility arises in contract, tort (including negligence), equity, breach of statutory duty, or otherwise. ‍7.2 Except to the extent permitted by law, nothing in these Terms has the effect of contracting out of the New Zealand Consumer Guarantees Act 1993 or any other consumer protection law that cannot be excluded. To the extent our liability cannot be excluded but can be limited, our liability is limited to NZD100.‍7.3 To the maximum extent permitted by law and only to the extent clauses 7.1 and 7.2 of these Terms do not apply, our total liability to you under or in connection with these Terms, or in connection with the Website, or your access and use of (or inability to access or use) the Website, must not exceed NZD100.‍8 PRIVACY ‍8.1 You are not required to provide personal information to us, although in some cases if you choose not to do so then we will be unable to make certain sections of the Website available to you. For example, we may need to have your contact information in order to provide you with updates from our Website. ‍8.2 When you provide personal information to us, we will comply with the New Zealand Privacy Act 1993 (NZ), the Privacy Act 1988 (Cth) and our Privacy Policy above. ‍8.3 Any personal information you provide to us may be stored on the secure servers of our trusted service providers, which may be located outside New Zealand or Australia. This may involve the transfer of your personal information to countries which have less legal protection for personal information other than New Zealand or Australia.‍9 SUSPENSION AND TERMINATION‍9.1 Without prejudice to any other right or remedy available to us, if we consider that you have breached these Terms or we otherwise consider it appropriate, we may immediately, and without notice, suspend or terminate your access to the Website (or any part of it).‍9.2 On suspension or termination, you must immediately cease using the Website and must not attempt to gain further access.‍10 GENERAL‍10.1 If we need to contact you, we may do so by email or by posting a notice on the Website. You agree that this satisfies all legal requirements in relation to written communications. ‍10.2 These Terms, and any dispute relating to these Terms or the Website, are governed by and must be interpreted in accordance with the laws of New Zealand. Each party submits to the non-exclusive jurisdiction of the Courts of New Zealand in relation to any dispute connected with these Terms or the Website.‍10.3 For us to waive a right under these Terms, the waiver must be in writing.‍10.4 Clauses which, by their nature, are intended to survive termination of these Terms, including clauses 4.5, 5, 6, 7, 10.1, continue in force.‍10.5 If any part or provision of these Terms is or becomes illegal, unenforceable, or invalid, that part or provision is deemed to be modified to the extent required to remedy the illegality, unenforceability or invalidity. If a modification is not possible, the part or provision must be treated for all purposes as severed from these Terms. The remainder of these Terms will be binding on you.‍10.6 These Terms set out everything agreed by the parties relating to your use of the Website and supersede and cancel anything discussed, exchanged or agreed prior to you agreeing to these Terms. The parties have not relied on any representation, warranty or agreement relating to the Website that is not expressly set out in the Terms, and no such representation, warranty or agreement has any effect from the date you agreed to these Terms.